Attention Charity Trustees!
New Legal Requirement to Submit Trustee Information from 30 June 2025
As part of new measures being introduced under the Charities (Regulation and Administration) (Scotland) Act 2023, OSCR has advised that from 30 June 2025, there will be a new legal requirement for all registered charities to provide details of their charity trustees.
What details are required?
The following information must be submitted via OSCR Online for each charity trustee:
- Full name
- Home address
- Email address
- Telephone number
- Date of birth
- Date of appointment as a charity trustee
How does my charity provide this information?
New charities registered on or after 30 June 2025 must provide this information as part of the OSCR application process.
Existing charities must include these details in their next annual return submitted via OSCR Online.
Will my details be publicly available on the OSCR website?
Until late 2025 (date TBC), the Scottish Charity Register will remain unchanged and will not publicly disclose any trustee information.
From late 2025, OSCR will publish only the first and last names of each charity trustee. All other information will be securely stored and used solely for regulatory and contact purposes.
Additionally, OSCR will begin publishing full annual reports and accounts for all charities on the Register. No further trustee details will be made public unless included in the submitted documents. Charities are encouraged to carefully review the content of their reports, and to only include names or images of volunteers or beneficiaries where necessary and appropriate.
What do I need to do next?
To ensure a smooth transition and compliance with the new rules, trustees should:
- Inform all trustees about the new requirements
- Collect the necessary trustee information as outlined above
- Ensure up to three designated individuals have access to OSCR Online
Are there any exemptions to the new requirements?
Trustees concerned about their safety can apply for an exemption to keep their name off the Register.
Applications for exemption open on 30 June 2025.
If an exemption is requested at the time of data collection, the name will not be published until a decision is made.
If the request is declined, the name will appear on the Register from late 2025.
Conclusion
This marks a significant shift from OSCR’s current approach, where only some charity accounts are published, and personal details are redacted.
The new measures under the Charities (Regulation and Administration) (Scotland) Act 2023 are a deliberate a 'catch-up' move towards transparency for Scottish registered charities, aligning with existing Charity Commission requirements to publish trustee details and annual returns / accounts.
This article was co-authored by Marnie Richmond, Trainee Solicitor in MFMac's Charities and Third Sector team.
